Justia Indiana Supreme Court Opinion Summaries

The defendant pleaded guilty to criminal confinement and interfering with reporting a crime, resulting in a five-year sentence: two years served through time already served and work release, followed by three years of probation. The plea agreement specified that violating any court-sponsored program, such as work release, would result in revocation and execution of the sentence. In 2023, the defendant failed to return to the work release facility, prompting his community corrections case manager to file a petition seeking revocation of his work release placement. The petition, however, did not mention probation or request revocation of the suspended portion of his sentence.After the defendant was later arrested and pleaded guilty to failure to return to lawful detention, the trial court addressed both the work release violation and, upon the State’s oral request, the defendant’s probation. Despite the defendant’s counsel objecting that revoking probation without a specific petition violated due process, the trial court revoked both his work release privileges and his probation, ordering the remainder of his sentence executed in the Department of Correction.On appeal, the Indiana Court of Appeals affirmed the trial court, holding that the court had statutory authority to revoke probation and that due process was satisfied through the plea agreement and the notice provided by the work release revocation petition. The defendant sought further review.The Indiana Supreme Court granted transfer, vacated the Court of Appeals opinion, and reversed the probation revocation. The Court held that due process requires that the State may only seek sanctions identified in the revocation petition or for which the defendant has actual notice. Because there was no petition or adequate notice seeking probation revocation, the trial court’s order revoking probation was improper. View "Ewing v. State" on Justia Law

Anthony Carter was accused of killing his girlfriend, Ashley Neville, in Columbus, Indiana. After a late-night argument, Carter entered Neville’s bedroom and shot her in the head. When she survived the gunshot, Carter strangled her with his hands, then placed a plastic grocery bag over her head and secured it with duct tape, ultimately suffocating her. Carter later confessed to his daughter and law enforcement, giving varying accounts about whether the shooting was intentional or accidental. Neville’s autopsy revealed death from both the gunshot wound and asphyxiation, with physical evidence supporting both causes.The State charged Carter with murder and sought a life without parole sentence, alleging three statutory aggravators: Carter was on probation for two felonies at the time, and he tortured Neville. During the jury trial in Bartholomew Superior Court 1, Carter argued that the shooting was accidental and requested a lesser-included instruction for reckless homicide, which the trial court declined, reasoning there was no serious dispute about Carter’s intent in the subsequent asphyxiation. The jury found Carter guilty of murder and all three aggravators, recommending life without parole, which the trial court imposed.Reviewing the direct appeal, the Indiana Supreme Court addressed whether the trial court erred in declining the reckless homicide instruction and whether sufficient evidence supported the torture aggravator. The Supreme Court held that the trial court did not abuse its discretion, as Carter’s intentional acts following the gunshot established murder rather than reckless homicide, regardless of the gunshot’s primary role. The Court also found sufficient evidence for the torture aggravator, citing Carter’s prolonged and gratuitous infliction of pain. Accordingly, the Indiana Supreme Court affirmed Carter’s conviction and sentence of life imprisonment without parole. View "Carter v. State of Indiana" on Justia Law

A man living in Muncie, Indiana, was charged with supplying another individual with counterfeit oxycodone pills (M30s) containing fentanyl, which were then sold to a seventeen-year-old who died from a fentanyl and cocaine overdose. The accused regularly sold M30s to the intermediary, who also obtained such pills from other sources. After the fatal incident, police recovered part of an M30 pill from the victim’s nightstand. During the investigation, the intermediary initially told police that the accused was the supplier of the fatal pills but later recanted, identifying another supplier. The State, planning to use the intermediary’s testimony, withdrew its immunity offer when the intermediary changed his account and decided not to call him as a witness, knowing he would invoke his right against self-incrimination.At the bench trial in Delaware Circuit Court, the prosecution introduced, over objection, the intermediary’s prior statement to police implicating the accused, but the defense was not given an opportunity to cross-examine the intermediary. The court found the accused guilty of multiple charges, including a Level 1 felony for aiding in dealing a controlled substance resulting in death. On appeal, the accused challenged the Level 1 felony conviction, arguing a violation of his Sixth Amendment right to confront the witness. The State conceded this violation but argued that the error was harmless. The Indiana Court of Appeals agreed with the State and affirmed the conviction.The Indiana Supreme Court granted transfer and reviewed whether the constitutional error was harmless beyond a reasonable doubt. The court concluded that the admission of the statement was not harmless, as it was the only direct, non-cumulative, and uncorroborated evidence linking the accused to the fatal pills, and the defense was denied cross-examination. The court vacated the Level 1 felony conviction and remanded for a new trial on that charge. View "Taylor v. State of Indiana" on Justia Law

A track and field athlete participated in the 2020 United States Olympic Trials, organized by USA Track & Field, Inc. (USATF), where she signed a waiver and indemnity agreement as part of her application to compete. During the heptathlon event, she suffered heat-related injuries on a day when temperatures were extremely high, preventing her from completing the competition and resulting in her not making the Olympic team. Seeking to pursue tort claims, the athlete first filed a declaratory judgment action in the Marion Superior Court, challenging the enforceability of the waiver agreement and seeking an injunction against its enforcement.The Marion Superior Court granted summary judgment to USATF, holding that the waiver agreement was enforceable and disposing of all claims. After the final judgment, but before the statute of limitations expired, the athlete moved to amend her complaint to add tort claims for negligence, gross negligence, recklessness, and willful misconduct. The trial court denied this motion, concluding that it was untimely because it was filed after entry of final judgment. The athlete appealed, and the Indiana Court of Appeals affirmed the enforceability of the agreement but held that the trial court had abused its discretion in denying the motion to amend, relying on Indiana Trial Rule 15(A).The Indiana Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion, and addressed the procedural issue. The Court held that once final judgment has been entered and all claims have been disposed of, Indiana Trial Rule 15(A) no longer allows for amendment of pleadings. A party may only seek to amend a complaint after final judgment if the judgment is first set aside or vacated under the appropriate rules. Accordingly, the Supreme Court affirmed the trial court’s denial of the motion to amend, clarifying that Rule 15(A) does not apply after final judgment. View "Brooks v. USA Track & Field, Inc." on Justia Law

Kortney Elzey, while serving a sentence for home improvement fraud in Huntington County Jail, filed a pro se petition for post-conviction relief. He requested that his petition be forwarded to the State Public Defender because he was indigent. The trial court denied both his request for referral and his petition for post-conviction relief. The record in this appeal involved multiple case numbers, and one appellate issue concerned credit time calculations.The Indiana Court of Appeals affirmed the trial court’s denial of credit time, and the Indiana Supreme Court granted transfer but summarily affirmed the Court of Appeals on that issue. Elzey argued that the trial court erred by not referring his post-conviction petition to the Public Defender. The State responded that, under the Indiana Rules of Post-Conviction Remedies, referral to the Public Defender is only required for petitioners incarcerated in the Department of Correction, not county jails.The Indiana Supreme Court held that, although the relevant statute (Indiana Code Section 33-40-1-2) requires the Public Defender to represent indigent petitioners confined in any “penal facility,” including county jails, the procedural court rule only required referral when the petitioner was in the Department of Correction. Because the trial court followed the rule as written, no reversible error occurred. The Supreme Court recognized a gap between the statute and the rule and referred the matter to its Rules Committee to amend the rule so it applies to all penal facilities. The Court concluded that the Public Defender’s duty to represent applies to all indigent individuals confined in penal facilities, but procedural referral requirements must be updated. The Supreme Court affirmed the trial court’s decision and initiated rulemaking to address the identified gap. View "Elzey v. State of Indiana" on Justia Law

Kimberly Anderson was charged with three felonies after stabbing her boyfriend with a boxcutter and threatening to kill him. Before trial, she entered a plea agreement with the State, pleading guilty to two charges—felony domestic battery and felony intimidation. In exchange, the State dropped one charge, refrained from adding another, and agreed to a maximum executed sentence of four years, with the specific sentence left to the trial court’s discretion. The agreement included a provision in which Anderson waived her right to appeal any sentence imposed within the terms of the agreement.At the sentencing hearing in the Marion County Superior Court, the judge reviewed the plea agreement with Anderson, confirmed her understanding, and heard arguments from both sides regarding aggravating and mitigating factors. The court ultimately sentenced Anderson to three years executed and three years suspended to probation. After sentencing, the court mistakenly told Anderson she could appeal her sentence, prompting her to do so. Anderson’s appeal to the Indiana Court of Appeals argued that the trial court abused its discretion by considering improper factors and failing to recognize significant mitigating evidence. The State moved to dismiss the appeal based on the waiver, and a divided motions panel of the Court of Appeals dismissed the appeal. Anderson then sought transfer to the Indiana Supreme Court.The Indiana Supreme Court held that a sentence is “illegal”—and thus not subject to an appeal waiver—only if it is outside the statutory range or unconstitutional. Anderson’s sentence was within the statutory range and not unconstitutional; her arguments concerned alleged abuse of discretion, not illegality. The Court found the appeal waiver valid and comprehensive, and dismissed Anderson’s appeal. View "Kimberly R. Anderson v. State of Indiana" on Justia Law

Bedford Recycling, Inc. applied to the Monroe County Board of Zoning Appeals (BZA) for a conditional use permit to operate a scrap metal collection and sorting facility on property zoned for mineral extraction. The county’s zoning ordinance did not specifically allow scrap metal recycling, so Bedford sought approval under the category of “Central Garbage/Rubbish Collection Facility.” The BZA granted the permit after a public hearing in which Bedford acknowledged the facility would not handle solid waste, a typical requirement for the permit. Subsequently, Republic Services, a neighboring property owner, filed for judicial review, arguing that Bedford’s facility did not meet the ordinance’s requirements. While preparing written findings to support its decision, the BZA’s attorney concluded that granting the permit was a legal error, as Bedford’s proposed use did not fit the permit’s definition.After several meetings and changes in BZA membership, the Board voted to revoke Bedford’s permit, finding that the facility was essentially a scrap yard, which was not a permitted use in the zoning district. Bedford then sought judicial review in the Monroe Circuit Court, which found that the BZA lacked statutory authority to revoke the permit based on a change in reasoning or alleged legal error, and reinstated the permit. The Indiana Court of Appeals reversed, holding that the BZA could correct its own legal error and revoke the permit.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ decision. The Court held that administrative bodies like the BZA have only the powers expressly granted by statute and possess no inherent or common law authority to reconsider or revoke final decisions absent explicit legislative authorization. The Court disapproved prior appellate decisions that recognized an “error of law” exception. Accordingly, the Supreme Court affirmed the trial court’s order vacating the BZA’s revocation and reinstated Bedford’s conditional use permit. View "Monroe County Board of Zoning Appeals v. Bedford Recycling, Inc." on Justia Law

A commercial real estate broker and consultant partnered with three brothers who owned an architecture and construction company to develop and lease a commercial property. They planned to form a limited liability company (LLC) as equal members, contributing professional services and cash, but did not formalize their agreement in writing. After a dispute arose over a broker commission, the brothers executed a backdated operating agreement that excluded the broker from LLC membership. The broker alleged he was unfairly cut out of the deal and sued for breach of contract and unjust enrichment.The Marshall Circuit Court granted summary judgment to the brothers on the contract claim, finding that Indiana law required written confirmation for LLC membership, which the broker lacked. The court also denied the broker’s request for a jury trial on the unjust enrichment claim, holding that both the claim and the defense of unclean hands were equitable issues for the judge. After a bench trial, the court ruled against the broker on unjust enrichment, finding he failed to prove his claim and that unclean hands barred recovery.On appeal, the Indiana Court of Appeals reversed, holding that initial LLC membership could be established by oral agreement and that unjust enrichment claims for money damages were legal claims entitled to a jury trial. The Indiana Supreme Court granted transfer, vacating the appellate decision.The Indiana Supreme Court held that LLC membership under the Business Flexibility Act requires either a written operating agreement or written confirmation, and the broker was not a member as a matter of law. However, genuine factual disputes remained regarding whether the brothers breached an agreement to make him a member, precluding summary judgment. The Court also held that unjust enrichment claims for money damages are legal claims subject to a jury trial, and the unclean hands doctrine may be asserted as a defense. The judgment was vacated and the case remanded for a jury trial on both claims. View "Andrew Nemeth Properties, LLC v. Panzica" on Justia Law

A serious automobile accident occurred in June 2018 involving Tommi Hummel, who was insured by Standard Fire Insurance Company. The accident resulted in severe injuries to Bradley Baldwin and John Hopkins, both of whom were involved in the crash, while a third passenger, Jill McCarty, left the scene. Hummel’s insurance policy provided $50,000 per person and $100,000 per accident in bodily injury liability coverage. After the accident, Baldwin sued the Hummels for negligence and made a time-limited settlement demand for the $50,000 per-person policy limit. Standard Fire, recognizing that multiple claims could exceed the policy limits, rejected Baldwin’s demand and instead filed an interpleader action, depositing the $100,000 policy limit with the trial court and naming all potential claimants.The Marshall County Circuit Court granted summary judgment for Standard Fire, finding that it had not breached any duty to its insureds and was released from further liability. The Indiana Court of Appeals affirmed in part but reversed on the issues of breach of the duty of good faith and bad faith, holding that genuine issues of material fact existed regarding Standard Fire’s rejection of Baldwin’s settlement demand and its conduct in filing the interpleader action.The Indiana Supreme Court reviewed the case and affirmed the trial court’s grant of summary judgment for Standard Fire. The Court adopted Section 26 of the Second Restatement of Liability Insurance, establishing that an insurer facing multiple claims against insufficient policy limits fulfills its duty of good faith by filing an interpleader action, naming all known claimants, depositing policy limits with the court, and continuing to defend the insured. The Court held that Standard Fire’s actions satisfied this standard and did not constitute a breach of the duty of good faith or bad faith. View "Baldwin v. The Standard Fire Insurance Co." on Justia Law

An unwed couple had a child in July 2013. The father’s name was not listed on the birth certificate, and he died about a year and a half later. The child’s paternal grandmother remained involved in the child’s life and provided support to the mother. In 2018, the grandmother petitioned for visitation and to establish the father’s paternity, submitting a DNA report indicating a high likelihood of paternity. After a hearing, the mother and grandmother, both represented by counsel, submitted an agreed order to the Porter Superior Court. The mother agreed to change the child’s surname, add the father’s name to the birth certificate, and acknowledged in open court that the father was the child’s father. The trial court approved the agreed order.Subsequent disputes arose regarding visitation, leading to contempt motions and further hearings. The trial court maintained the agreed order, found the mother in contempt, and later appointed a guardian ad litem following additional petitions. At a final hearing, the guardian ad litem recommended joint legal custody with the grandmother as primary custodian. The trial court requested briefing, after which the grandmother filed her brief and the mother moved to dismiss the visitation petition, arguing the grandmother lacked standing under the Grandparent Visitation Act (GVA). The trial court denied the mother’s motion, finding she had waived any challenge to standing by stipulating to the agreed order. The Indiana Court of Appeals reversed, holding the grandmother lacked standing because paternity had not been formally established.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ decision. The Supreme Court held that the mother was equitably estopped from denying the father’s paternity due to her prior stipulations and conduct. Therefore, the grandmother had standing under the GVA to petition for visitation. The Supreme Court affirmed the trial court’s judgment. View "O'Connell v. Clay" on Justia Law